Last changed: November 2020
The usage of benni.games (owner: Benjamin Wegener) and all services, products, apps and mobile games provided by benni.games (owner: Benjamin Wegener) can have the saving and processing of personal data with it.
To make this data processing and saving as transparent, comprehensible and fair as possible, we inform you about your rights within the General Data Protection Regulation (GDPR) which took effect by may 25th 2018.
Responsible for the collection, processing and usage of personal data for the purpose of Art. 4 #7 GDPR is Benjamin Wegener, Benjamin Wegener, Calçada de Santa Clara 30 (Apt 4-A), 9000-036 Funchal, Portugal (further called as "benni.games", "we" or "us").
To make use of your rights, for questions, feedback or any other type of need to contact us, please use the e-mail address firstname.lastname@example.org.
Printing and/or saving
You're allowed to print or save this privacy statement for your personal use.
Definition of terms
To prevent missunderstandings and to make everything as clear as possible we need to define all terms with it's meant definition/description. If you are finding a not defined term and want us to add it to the list, please feel free to contact us under the e-mail-address under "contact channels".
- internet provider – the company which provides you your access to the internet.
- IP-address – an unique identifier number your internet provider assigned your internet access to identify your internet access point, your computer and any other device you're using to access the internet
- Hoster – the company which provides us the necessary processing power, online storage and anything else for providing these online services.
- GDPR – stands for "General Data Protection Regulation" and took effect on 25th of may 2018 . This law should secure the personal data by any consumer/visitor and any private person which will be saved and processed by companies in europe. it will achieve this by strict paragraphs to reduce the amount of processed and saved data to a bare minimum.
- Cache – this storage will save any data which might are required to be loaded again soon. Your computer will save all temporarily saved internet files within this cache to prevent to load these resources again after you reloaded the page or anything like that.
- e-mail-provider – the company which will provide products and services to receive and send e-mails to other e-mail addresses.
- Libraries – Libraries are packages of software to fulfill a specific task and allows the developer to don't have to reinvent the wheel by just using this specific libary.
- In-App purchases – by this are meant all purchases made within in an app which will charge you real money for digital goods like coins, storage or anything provided by the regarding app.
data collection and -processing within the usage of our website
For us to be able to provide you with our web service we are required to make use of hosting services to fulfill our infracstructure and plattform services, computing capacity, online storage and database services, safety services, as well as technical maintenance services, which are necessary to provide our website by one of our partners digitalocean (DigitalOcean LLC). Our choosen partner digitalocean (DigitalOcean LLC) provides an online FAQ about their measures, actions and steps to fulfill the requirements of GDPR We defined the location of all our servers to be in europe. GDPR-FAQ of digitalocean As far as possible by ourselves we configured the access and error logs to only save anonimized data. Our decisions are based on our legitimate interests for an efficient and save providing of our online services like our website on the purpose of Art. 6 Abs. 1 S. 1 f) GDPR i.V.m. Art. 28 GDPR.
Minimizing data collection and processing
benni.games always trys to collect and process as less personal data as possible and only based on our legitimate interests. With this in mind we don't use external analytics tools to track traffic, access and/or other information about the usage of our website. By clicking on a benni.games link to our website from one of our mobile apps (apps or mobile games) we add specific query parameters to the url to track information about your used platform (iOS or Android) and your used language. This will allow us to identify the primary market (platform-wise) and will let us plan future releases and translations for our new mobile games, apps, services and products. Furthermore will this be helpful to show you the shown website in the prefered language as far as an possible translation will be available, as well as give us the opportunity to translate the website and all shown informations in language we didn't knew would be relevant to our user base.
Your contact attempts
If you send us an e-mail to one of our e-mail-addresses the contained information will be stored and processed within your requested context and for future dialog purposes by benni.games and one of it's associates. benni.games uses an e-mail-provider, within the product GSuite, of on of our partners Google LLC (formerly known as Google Inc.), 1600 Amphitheatre Parkway, Mountain View, California 94043 USA which was instructed by benni.games for data processing and storage of incoming as well as outgoing e-mails and conversations through the servers of Google LLC. This decission was based on our legitimate interests in purpose of Art 6 Abs. 1 S. 1 f) DSGVO. More personal data are only saved and processed when you explicitly tell us to or we have an legitimate interest to do so.
Storage of personal data
If not stated otherwise, we will only save and process personal data for the stated purposes and the necessary processing and storage purposes. As far as it will be able for us, we're trying to delete all unneeded and unused personal data automatically through our automated systems.
To play our games or use our services you must be over a certain age. benni.games do not knowingly collect personal data from or direct or target interest based advertising to anyone under the ages set out below, or knowingly allow such persons to use our Services. If you believe that we might have any information from or about a child under the age set out below, please Contact Us.
|Country||Age you must be to play our games or use our services|
|Republic of Cyprus||14|
|Rest of the world (excluding South Korea)||13|
For newsletter sign ups we're using the double opt-in procedure in which you're required to accept your registration in one of our mailing lists and after you send your request, we will automatically send you an e-mail with an confirmation link you're required to click to legitimize your entry in one of our mailing lists. With your click on our activation link we have your explicit permission to send you our future newseltter issues.
Mobile Games, Games & Apps
The main product of benni.games are games like mobile games for mobile devices (Apps) as well as computer-games for devices like personal computers (pc), mac or otherwise listed devices. To improve those games, to optimize them and/or to extend our software we're required to make use of software to measure, analyse and optimize our products. This part will inform you about the collection, processing and storage of data which can (in most cases won't) contain personal data.
Some information are already processed in an automatically fashion as soon as you download and use our apps and mobile games. We will list you the exact personal data we process for you:
Information that is collected during app download
When downloading our products, certain required information will be transmitted to the app store you have selected (e.g. Google Play, Apple App Store, and such); in particular this may include:
- your username,
- email adress,
- customer account number,
- the time of download,
- the payment information
- and any individual device code
These information are exclusively processed by your selected app store in question and this processing is beyond our control.
Information collected automatically
In some cases as part of using one of our products we automatically may collect certin information that is required in order to let you use our product. This may include (in some cases; if especially stated):
- your username,
- e-mail address,
- customer account number,
- your device,
- mobile advertising ID,
- your user ID,
- the model/type of your used device,
- the version of your used operating system,
- registration dates when you registered with up through our product,
- login dates when your last log in,
- usage dates and durations you used our product,
- transactional data as far as you booked subscriptions and such with us and we have an active contract,
- contract histories
By analysing the usage and distribution of our software, we're able to optimize, extend and improve our software. With "Unity Analytics", a library and software package of one of our partners Unity Technolgoies (Unity Software Inc.), we're able to improve, extend and optimize our software, which is why we implemented this package at the necessary places it makes sense to track the data. With this setup we achieve an optimized overview and analytics data about the usage and distribution of our software (mobile games, apps and games). Unity Analytics will collect game data as well as device data to show the developer (us) all necessary information about the game and all data related to it. Information Unity Analytics obtain from these devices includes:
- Device attributes: information such as the operating system, hardware and software versions, platform, screen size, and CPU/graphics characteristics.
- Usage data: information about how you use the application. For example, day of first session, day of last session, session length.
- Location data: specifically, the country.
- In-app purchase data: if you perform financial transactions (such as when you make a purchase in a game), we collect information about the purchase. This includes purchase amounts and number of purchases.
- **Custom event game data these are specific in-game events that some games collect, and are contextual to the game. For example, level start, enemy count, player health are all examples of custom event data.
- Identifiers and network: device IDs and IP address. Note that for security purposes, we do not expose this information.
Our games are free to use and to provide this service for free, we're required to implement ads. For this purpose we implement the Service "Unity Ads" by our partner Unity Technolgoies (Unity Software Inc.). To display you the best ads, this service tries to show you personalized ads based on your preferences. This means, that your personal identifier is used to measure your behaviour and track your interests based on displayed ads in the past to show you more relevant ads in the future. For this purpose, Unity Ads creates a profile for your interests to show you more personalized ads. To control/change and disable this feature you can tab on the privacy settings button in our games which allows you to download and delete your data saved at Unity Ads and to disable this feature. This button opens an online link on the websites of Unity Technologies on which you can let them send you all your previous collected data and furthermore let you delete all saved data. It also allows you to deactivate this tracking based on your unique identifier of your device. Please consider, that disabling this behaviour and deleting your data won't disable ads within our games. It will only result in non personalized ads displayed by this service which might sometimes might not feel fitting with your interests.
Your rights as affected person
We will now inform your about your rights as affected person of data collection and processing. If you want to make use of one of your rights, please feel free to send your request to our address listed under "Contact channels" and please keep in mind our information under "Your contact attempts".
Rights of Confirmation and information
You have the rights to request an confirmation of us when your personal data are processed and/or stored by us. If so, you've got the right to get all necessary information about the saved and processed personald data as well as an copy of those data. Furthermore you have the rights to get all information about:
- the processing purposes;
- the category of personal data, which are processed;
- the receipient or category of receipient, which are allowed to view and process personal data or are getting permission to process personal data in the future. This includes especially receipients within third countries or international organizations;
- if possible, the duration, the personal data will be saved or the criteria the duration is based on;
- if there is a right for correction or deletion of your personal data or if there are restrictions for processing through the responsible person or if there is an right to object against this processing;
- if you have the right to complaint at an specific supervisory authority;
- if the personal data are not received by you, the information about the source(s) of those personal data;
- the existence of an automated decision making based on profiling in purpose of Art 22 paragraph 1 and 4 GDPR and - at least in these cases – specific information about the logical algorithms these decisions are based on, as well as the information about how far this decision will take effect in your experience with our products/services and such.
As far as personal data are shared with third countries or international organizations, you've got the right to get informed about the guaranties in purpose of Art. 46 GDPR in context of transferring and sharing.
Right of Rectification
You have the right, to request an rectification your personal data as well as the completion of incomplete personal data - even with an complementary confirmation.
Right of "to be forgotten" (Deletion)
As far as no law, retention periods or similar legal provision takes effect and we don't have other legitimate interests in further processing your personal data (i.e. public interest), you have the right to request the deletion of your personal data as far as it is technically and logically possible by us. Furthermore will this result in an obligation of ours to inform our partners about the deletion and trigger the deletion for their data storages as well of your personal data as far as it is technically and logically possible and won't collide with contacts and task fulfillments.
Rights to restrict processing
You have the rights to restrict the processing of your personal data by us as far as these conditions are valid:
- When you deny correctness of personal data, for an duration which will allow us to confirm an possible incorrectness of your personal data.
- When the processing isn't legal and you denied the deletion of your personal data by requesting the restriction of processing of your personal data.
- When we don't need your personal data anymore but you need them for legal purposes.
- When you objected the data processing in purpose of Art. 21 Abs. 1 GDPR, as far as there are no legitimate interests from us, which are more valid.
Right to data portability
You have the right all personal data saved and processed by us to be ported You have the right to receive all personal data relating to you that you have provided to us in a common and machine-readable format. Furthermore, you have the right to transmit this data to another person responsible without hindrance from us, provided that
- the processing is based on consent in accordance with Art. 6 Paragraph 1 Sentence 1 a) GDPR or Art. 9 Paragraph 2 a) GDPR or on a contract in accordance with Art. 6 Paragraph 1 Sentence 1 b) GDPR and
- the processing is carried out using automated procedures.
This right includes the possibility of having the personal data transmitted directly from us to another person responsible, insofar as this is technically feasible and economically feasible by us.
Right to object
You have the right to object to the processing of your personal data. From then on, the data will no longer be processed by us.
Automatisierte Entscheidungen, sowie Profiling
On the part of benni.games there is no automated decision-making based on personal data. Furthermore, this type of decision-making is not supported or planned by benni.games.
Transfer of data to third parties
In principle, personal data collected on our part is only used explicitly in our own company. If, on our part, any third parties (such as logistics or hosting companies) are involved in the performance of our tasks and contracts, they will only receive the personal data to the extent that is necessary for the transmission and in the context of the service to be provided. If certain parts of the data processing are outsourced on our part (order processing), we oblige the associated partner to use and process personal data only in accordance with the requirements and guidelines of the data protection laws and to protect and guarantee the protection of the rights of the data subject. A transfer of personal data to companies, institutions or persons outside the EU outside of the use cases mentioned in this declaration does not take place and is not planned.
Amendments to this Privacy Statement
Since we're keeping this privacy statement up to date we therefore, reserve the right to amend it from time to time and to make changes to the collection,, processing and use of your personal data about which we will inform you in an specific part of the privacy statement. The current version of this privacy statement is always available under "Privacy Statement" within our products.